Stahl v. Target Corporation, No. 2:2015cv01681 - Document 23 (D. Nev. 2016)

Court Description: ORDER Granting 21 Unopposed Motion to Extend Time to Respond re 20 Motion for Summary Judgment. Responses due by 10/19/2016. Signed by Magistrate Judge George Foley, Jr on 10/18/16. (Copies have been distributed pursuant to the NEF - MMM)
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Stahl v. Target Corporation Doc. 23 Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 1 of 6 1 2 3 4 5 6 APPL WILLIAM R. KILLIP JR., ESQ. Nevada Bar No. 3660 NETTLES LAW FIRM 1389 Galleria Drive, Suite 200 Henderson, Nevada 89014 Telephone: (702) 434-8282 Facsimile: (702) 434-1488 bill@nettleslawfirm.com Attorneys for Plaintiff 7 Lfl1iUI]1WUJ]KttitIIZEI1$HU 8 Ii] 9 L41S1 CASE NO. 2:15-CV-01681-RFB-GWF 10 11 Plaintiff, 12 ci oo Z r"i ’ c - 5 O -. 00 16 VS. TARGET CORPORATION; DOE INDIVIDUALS 1 through 10; ROE CORPORATIONS 11 through 20; and ABC LIMITED LIABILITY COMPANIES 21 through 30; 17 Defendants. 18 19 20 DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 21 (First Request) 22 23 24 25 26 27 28 Plaintiff Deanna Stahl ("Ms. Stahl") by and through her attorney William R. Killip, Jr. Esq., of the Nettles Law Firm, hereby moves this Court, pursuant to LR IA 6-1 and LR IA 6-1 ol the U.S. District Court, District of Nevada Local Rules of Practice, for an extension of time to fih Plaintiffs Opposition to Defendant’s Motion for Summary Judgment. Defendant’s Motion Summary Judgment was filed on September 23, 2016. This motion is made and based on all pleadings and papers on file herein and the following Points and Authorities. I/I 51 Dockets.Justia.com Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 2 of 6 ri I iiva i 1 s& lii V I I ri lull II flIjI 2 3 4 5 6 7 8 9 10 11 12 STATE OF NEVADA COUNTY OF CLARK 1. I am the attorney for Deanna Stahl, the plaintiff herein. I have personal knowledge of th facts set forth in this affidavit. If called upon to do so, I could competently testify as to the matte] stated herein. 2. On October 17, 2016, my office spoke with Defendant’s counsel Douglas M. Rowan, Esq regarding an extension of time to file Plaintiffs Opposition to Defendant’s Motion for Summar) Judgment. 3. The parties agreed upon an extension to October 19, 2016 for the filing of Plaintiff Opposition. 4. j > ,. ) ) ss: ) Due to the lateness of the hour, Plaintiff files an unopposed Motion to extend the time tc file Plaintiffs Opposition to October 19, 2016. i ;- oo 16 5. I declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct. .17 18 19 20 21 22 23 24 25 26 27 28 SUBSCRIBED AND SWORN to before me tls L( dayo.f October, 2016. LIC r NOTARY p STATE OF NEVADAWLWry CF CLAW MY App "M UP MAY a 2020 No: OO41i Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 3 of 6 UI] Iii IVWthi :isui UI 3 1 2 3 4 This arises from a personal injury incident while Plaintiff was shopping at the Target ston 5 located at 4100 Blue Diamond Road in Las Vegas, Nevada ("the Premises"). On August 30, 2013 6 Plaintiff was purchasing some plastic containers at the cash register when she noticed the item 7 she intended to purchase were broken. Due to the length of time Defendant’s employees wer 8 taking to bring new containers to the register, Plaintiff informed the cashier she would go get ne 9 containers to purchase herself. While Plaintiff was walking towards the isle where the container 10 were located, she slipped and fell on a puddle of clear liquid located on the floor in the area of th _11 greeting cards. Plaintiff sustained serious injuries as a result. 12 On September 23, 2016, Defendant filed its Motion for Summary Judgment on the ground 13 that there is insufficient evidence upon which Plaintiff can established a cause of action o 4 Summary Judgment is due on October 17, 2016. cQ - negligence against Target as a matter of law. Plaintiffs Opposition to Defendant’s Motion - OO oo cq Cq r- 16 17 T 18 Plaintiffs seeks a two day extension of time to file her Opposition to Defendant’s 19 for Summary Judgment. On October 17, 2016, Plaintiffs counsel’s office spoke with defens 20 counsel Douglas M. Rowan, Esq. by telephone regarding an extension to file Plaintiff! 21 Opposition. The parties were in agreement to extend Plaintiffs filing date to October 19, 2016 22 Due to the lateness of the hour, Plaintiff files this unopposed motion for an extension to fib 23 Plaintiffs Opposition to Defendant’s Motion for Summary Judgment by October 19, 2016. 24 Affidavit of William R. Killip, Jr., Esq., attached hereto. 25 26 27 III 28 III -3- Se Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 4 of 6 III. I 2 3 4 5 CONCLUSION , Plaintiff respectfully request that this Honorable Court grant an extension of time to Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment. DATED this day of October, 2016. NETTLES LAW FIRM 6 7 8 By: 9 10 11 CD 12 C,DC" o’, >> 14 WILLIAM R. KILLIP .JR...ESQ. Nevada Bar No. 3660 1389 Galleria Drive, Suite 200 Henderson, Nevada 89014 Telephone: (702) 434-8282 Facsimile: (702) 434-1488 kffl,nettlesIawfirrn.com Attorney for Plaintiff 15 16 IT IS SO ORDERED: 17 r- 18 19 UNITED STATES DISTRICT COURT CLERK UNITED STATES MAGISTRATE JUDGE 20 DATED: October 18, 2016 21 22 23 24 25 26 27 28 In Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 5 of 6 1 CERTI ? WATE OF SERVICE 2 3 4 I hereby certify that on the of the above and foregoing Unopposed Motion to Extend Time to Defendant’s Motion for Summary Judgment 5 6 7 8 9 10 12 Facsimile: (702) 727-1401 Kym Samuel Cushing, Esq. Douglas M. Roman, Esq. WILSON, ELSER, MOSKOWITZ, EDELMAN DICKER LLP 300 S. Fourth St., 11 fl. Las Vegas, Nevada 89101 Attorney for Defendant [ ] Hand Delivery oc ’k [ Facsimile Transmission z [t] U.S. Mail, Postage Prepaid [ ] Certified Mail, Receipt No. [ ] Return Receipt Requested 15 16 17 18 19 20 21 22 23 24 25 26 27 28 October, 2016, that I served true and correct copie File Plaintiffs Opposition t on all interested parties, addressed as follows: Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 6 of 6 Total Time: 000119 Job No.: 115330 Page: 005 Complete Document: doc20161017182157 It UNITED STATES DISTRICT COURT DISTRICT OF NVADA No. Date and Time Destination Times Type 001 10/17/16 18:22 7027271401 00119" FAX Result Resolution/ECM OK 200x100 Normal/On [ OHYOZ05300 ]